In a study produced by Dr. Bhattacharya (2009) regarding the ISM code on the management of occupational health and safety in the maritime industry four (4) key findings have been raised questioning its effectiveness.
The first issue that has been identified is the fact that both players (managers and seafarers) involved in the implementation of the ISM code have different perception on the subject. The managers of the shipping companies utilize the ISM code as a managerial tool which is going to improve and promote a safe and healthy working environment onboard their ships. However on the other side seafarers view the ISM code as a bureaucratic formality and burden with little impact in the promotion of a health and safe working environment since as the same study indicates, seafarers rely on their working experience gained and through their daily interaction with their colleagues. Moreover it can be said that the written procedures and guidelines produced by the managers were insufficient.
The second issue that has been raised is the difference in the methodology used in the implementation of the ISM code. The main practices that are being followed to demonstrate compliance with the ISM code is risk assessment, incident / near miss reporting and audit / review. The mentioned study revealed that even though managers and seafarers are able to demonstrate documented compliance with the above mentioned practices, it can be said that there is a difference between its purpose and what it achieved in practice, due to the fact that seafarers involved in risk assessment and incident/near miss reporting practices consider it unnecessary and they produce the necessary documents in order to be showed in compliance with Managers’ requirements and in some cases to avoid penalization. Another contributing factor is the reluctance in reporting incidents/near misses mainly to avoid the occurrence of discrediting their colleagues.
Regarding the audit/review the practice that is used from the Managers is yet insufficient since it is focused on documents review and effective paper trailing to demonstrate compliance with the ISM code and not considering the actual understanding and purpose of the ISM code. In addition to the above other players of the shipping industry such as Port State Control Officers and Charterers through vetting inspectors rely on the documentation to examine the level of ISM code implementation within an organization and onboard ships.
The third issue that arises from the same study is the participatory level of Managers and seafarers and in particular their involvement in the implementation of the ISM code. It has been identified that Managers while preparing their documented procedures and guidelines did not consider to use a more elaborated approach by requesting the active involvement of their seafarers while developing these procedures neither have been asked to share their knowledge and experience for further improvement of the...